Marcus DW Steel Principal Application Engineer Wave... · Supported by up to $5.5 million funding...

Version 1.2 15 May 2015

STEEL WAVE POWER ABN: 72 044 918 897

15 May 2015 Attention: Mr Chris Pattas, General Manager - Networks Branch Australian Energy Regulator GPO Box 520 Melbourne VIC 3001 mailto: [email protected] Dear Sir,

Response to AER: Tasmanian Framework and Approach preliminary positions

I refer to the AER's preliminary positions on a replacement framework & approach published on 2 April 2015 (AER reference: AC 046/15) with an invite for submissions by 15th May 2015. Yours Sincerely,

Marcus DW Steel

Principal Application Engineer

Steel Wave Power (SWP)

ABN: 72044918897

References:

a) Review of RO Banding for Small-Scale Renewables; A Report for the Department of Enterprise Trade and Investment; January 2014, Final Report; Prepared by: Cambridge Economic Policy Associates and Parsons Brinckerhoff

b) Development of a Small Scale Feed-In Electricity Tariff for Northern Ireland; Northern Ireland Department of Enterprise, Trade and Investment; June 2013, Final Report; Submitted by: Cambridge Economic Policy Associates (CEPA) Ltd; In association with: Sinclair Knight Merz (SKM)

c) Determination of the Appropriate Form of Support for Incentivising the Development of Renewable Electricity Generation in Northern Ireland; The Department of Enterprise, Trade and Investment and Northern Ireland Authority for Utility Regulation; August 2010, Final Report; Submitted by: Cambridge Economic Policy Associates Ltd in association with Parsons Brinkerhoff

mailto:[email protected]



Attachment 2 - Steel Wave Power’s Response to AER: Tasmanian Framework and Approach preliminary positions

The interpretation of the TUoS in the ‘framework & approach’



Imbalance of Negotiating Power



Subject: World-leading technology to power Flinders Island

4 March 2015

Tasmanian innovation will see the majority of Flinders Island’s energy needs supplied by renewable energy within two years. Hydro Tasmania will soon start work on developing a "Hybrid Energy Hub" on Flinders Island that will significantly increase

renewable energy use on the island and reduce the use and importation of diesel.

“Like many remote or island locations, Flinders Island is currently heavily reliant on expensive diesel fuel to supply its electricity needs,” said Project Director Simon Gamble.

“Diesel fuel remains the single largest expense in these remote systems and using renewable energy makes good economic sense.”

Development of the Hybrid Energy Hub follows the success of the King Island Renewable Energy Integration Project (KIREIP), which has seen King Island’s energy needs supplied solely from renewables when conditions allow, a world-leading

breakthrough. KIREIP uses a range of renewable and conventional technologies to reduce diesel consumption for power generation on the

island. The hybrid power system is comprised of wind, solar, battery storage, flywheels, dynamic resistor technology, dynamic load control and the use of biofuels.

“This combination of technologies means KIRIEP can securely and reliably generate power for King Island, even during lulls in

the wind or when the sun isn’t shining. When conditions are right, KIREIP delivers 100 per cent of King Island’s power from renewable sources, reducing the cost of providing electricity to the island,” Mr Gamble said.

Supported by up to $5.5 million funding from the Australian Renewable Energy Agency (ARENA), the $12.88 million Flinders Island project is the next step in off-grid hybrid system development. The hybrid system will be capable of displacing up to

60% of the annual diesel fuel used on the island to generate electricity. It involves integration of wind and solar generation with the existing diesel power station, and installation of enabling

technology, such as flywheel and battery energy storage, in a new form designed to drive down the cost of these systems. Hydro Tasmania’s has worked with Tasmanian manufacturers to develop a series of modular units to house and ship the

enabling technologies essential to the energy solution. This innovation will be developed and tested for the first time through the Flinders Island Hybrid Energy Hub project.

These modular enabling units will provide a lower-cost and scalable solution that will allow easy and rapid transport and installation for renewable energy projects, and which could also serve temporary uses such as in disaster relief or in the

mining industry.

Fabrication and testing of equipment takes place off-site, ensuring a speedy roll-out at the final location, reducing the risk, cost and duration of construction.

“The combination of our hybrid energy solution and the state’s skilled fabrication industry positions Tasmania well to supply these hybrid systems to a growing market throughout our region,” Mr Gamble said.

One such opportunity is Energy Developments Limited’s Coober Pedy project, incorporating wind, solar and enablers, which aims to achieve a 70 per cent reduction in diesel fuel used for power supply to the township of Coober Pedy. Hydro

Tasmania has been assisting EDL with the development phase of this project which would make use of the Tasmanian designed and manufactured modular enabling units if it proceeds to implementation.

The Flinders Island Hub project is due for completion in November 2016. Ends Released by Samantha Meyer, (03) 6230 5746



The level playing field objective

In relation to what Steel Wave Power was discussing implementing NER clause 6.6.4 for small-scale renewable incentive, Australian Energy Regulator has a greater knowledge and resources in this matter and References a), b) and c) under signature block of covering letter for Attachment 2. Steel Wave Power and allies won’t progress Decentralised Energy Systems in Tasmania without banding that is structured as follows and avoids double dipping on customers:-

Green Scheme Size Band

Small-scale Renewable Energy Scheme (SRES) less than 100kW

NER clause 6.6.4 “small-scale incentive scheme” between 100kW and 5MW

Large-scale Renewable Energy Target (LRET) greater than 5MW

Hydro Tasmania’s solution for King Island and Flinders Island is centralised. It is a key differentiator between philosophy of Proprietor of Steel Wave Power and powers that be in Hydro Tasmania that developed this diagram for Flinders:-



BOM declaring new El Nino for Australia has relevance in certain regions in Solar PV Power Output for “quite a substantial El Nino event”.



Steel Wave Power methodology was to compare against “Network costs” since awaiting QCA’s tariffs to include remaining costs e.g. energy, retail where “Network costs” means “SToUE (100% LRMC) tariff”.



The introduction of mandatory compliance programmes

Steel Wave Power is concerned about the cost of implementing the mandatory compliance programmes arises from Queensland precedent with zero export devices that have developed a commercial eco-system in Queensland. Steel Wave Power is not aware of any such zero export devices imposed within Essential Energy’s jurisdiction. When Steel Wave Power hears DNSP and their preferred suppliers talking about mandatory compliance with zero export devices, Steel Wave Power is wary about whose wealth they are creating: yours or theirs. Verification costs also can easily become a legal and widespread scam where regulator and rule makers haven’t done enough to shut down loopholes that DNSP employees have exploited with management sanction. This is not one or two rogues. If it were, Australian Energy Regulator could act and move on.



The timetable for implementation of the programme.

Proprietor of Steel Wave Power was an employee of Hydro Tasmania from 1997 through to 2010 when a redundancy was enforced during staff reductions. In

a) Hydro Electric Corporation, then b) Hydro Tasmania, Transend Networks and Aurora Energy, then c) Hydro Tasmania, Tasmanian Networks Pty Ltd.

we are talking about the culture of an industry that seemed to not care about how them making money estranged community from which they were making money. Tasmania is very vulnerable to phenomena of existing customers going off-grid due to their rugged resilience not commonly found amongst metropolis people. On North Stradbroke Island, I have seen Energex re-ingratiate themselves using their deep pockets (compared to an embedded generator developer) to an estranged community triggered by a rather mild ‘anti-Energex’ submission from Steel Wave Power to Queensland’s 30-year electricity strategy discussion paper. https://www.dews.qld.gov.au/policies-initiatives/electricity-sector-reform/submissions-received

Basically, Queensland majority will is to burn coal rather than utilise renewables. Basically, Tasmania’s majority will is to utilise renewables rather than burn coal. Proprietor of Steel Wave Power resides on North Stradbroke Island yet retains close linkages with fellow electricity industry professionals and para-professionals in Tasmania in attaining Principal Consultant in Hydro Tasmania. From 2010-2014, many excellent electricity industry professionals were shed from Hydro Tasmania, Transend Networks and Aurora Energy. Incumbent Tasmanian Government understands that population stagnation and talent drain is stagnating Tasmanian economy. There is a window of opportunity to establish new connection agreements correlated to 60/40 split (Hydro Tasmania / Community Resilience Microgrids) for just regional Tasmanian townships by Decentralised Energy Systems with hot-standby power for very large scale events. When fitting, proprietor of Steel Wave Power would return to Tasmania. In terms of social licence to build Decentralised Energy Systems on “remote” Bruny Island and Bicheno in Tasmania, three areas studied were unfeasible to co-locate generation and energy storage.

End of Steel Wave Power’s submission

https://www.dews.qld.gov.au/policies-initiatives/electricity-sector-reform/submissions-received

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